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Income Taxes
12 Months Ended
Dec. 31, 2024
Income Taxes [Line Items]  
Income Taxes

Note 20. Income Taxes

A reconciliation of reported income tax expense for PSEG with the amount computed by multiplying pre-tax income by the statutory federal income tax rate of 21% is as follows:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Years Ended December 31,

 

 

 

PSEG

 

2024

 

 

2023

 

 

2022

 

 

 

 

 

Millions

 

 

 

Net Income

 

$

1,772

 

 

$

2,563

 

 

$

1,031

 

 

 

Income Taxes:

 

 

 

 

 

 

 

 

 

 

 

Operating Income:

 

 

 

 

 

 

 

 

 

 

 

Current Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

(225

)

 

$

144

 

 

$

262

 

 

 

State

 

 

15

 

 

 

19

 

 

 

(30

)

 

 

Total Current

 

 

(210

)

 

 

163

 

 

 

232

 

 

 

Deferred Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

129

 

 

 

109

 

 

 

(335

)

 

 

State

 

 

140

 

 

 

253

 

 

 

80

 

 

 

Total Deferred

 

 

269

 

 

 

362

 

 

 

(255

)

 

 

ITC

 

 

(6

)

 

 

(7

)

 

 

(6

)

 

 

Total Income Tax Expense (Benefit)

 

$

53

 

 

$

518

 

 

$

(29

)

 

 

Pre-Tax Income

 

$

1,825

 

 

$

3,081

 

 

$

1,002

 

 

 

Tax Computed at Statutory Rate @ 21%

 

$

383

 

 

$

647

 

 

$

210

 

 

 

Increase (Decrease) Attributable to Flow-Through of Certain Tax Adjustments:

 

 

 

 

 

 

 

 

 

 

 

State Income Taxes (net of federal income tax)

 

 

122

 

 

 

215

 

 

 

41

 

 

 

Uncertain Tax Positions

 

 

95

 

 

 

(14

)

 

 

(22

)

 

 

NDT Fund

 

 

21

 

 

 

26

 

 

 

(22

)

 

 

Plant-Related Items

 

 

5

 

 

 

(7

)

 

 

(6

)

 

 

Tax Credits

 

 

(361

)

 

 

(10

)

 

 

(10

)

 

 

Audit Settlement

 

 

 

 

 

(7

)

 

 

 

 

 

Leasing Activities

 

 

 

 

 

(22

)

 

 

 

 

 

GPRC-CEF-EE

 

 

(52

)

 

 

(52

)

 

 

(37

)

 

 

TAC

 

 

(145

)

 

 

(232

)

 

 

(193

)

 

 

Bad Debt Flow-Through

 

 

(14

)

 

 

(9

)

 

 

(1

)

 

 

Other

 

 

(1

)

 

 

(17

)

 

 

11

 

 

 

Subtotal

 

 

(330

)

 

 

(129

)

 

 

(239

)

 

 

Total Income Tax Expense (Benefit)

 

$

53

 

 

$

518

 

 

$

(29

)

 

 

Effective Income Tax Rate

 

 

2.9

%

 

 

16.8

%

 

 

(2.9

)%

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The following is an analysis of deferred income taxes for PSEG:

 

 

 

 

 

 

 

 

 

 

 

 

 

As of December 31,

 

 

 

PSEG

 

2024

 

 

2023

 

 

 

 

 

Millions

 

 

 

Deferred Income Taxes

 

 

 

 

 

 

 

 

Assets:

 

 

 

 

 

 

 

 

Regulatory Liability Excess Deferred Tax

 

$

314

 

 

$

339

 

 

 

OPEB

 

 

49

 

 

 

58

 

 

 

Bad Debt

 

 

43

 

 

 

57

 

 

 

Corporate Alternative Minimum Tax (CAMT) Credit Carryforward

 

 

 

 

 

44

 

 

 

Operating Leases

 

 

38

 

 

 

42

 

 

 

Other

 

 

147

 

 

 

129

 

 

 

Total Assets

 

$

591

 

 

$

669

 

 

 

 

 

 

 

 

 

 

 

 

Liabilities:

 

 

 

 

 

 

 

 

Plant-Related Items

 

$

5,084

 

 

$

4,850

 

 

 

New Jersey Corporate Business Tax

 

 

1,414

 

 

 

1,284

 

 

 

Leasing Activities

 

 

33

 

 

 

35

 

 

 

AROs and NDT Fund

 

 

281

 

 

 

250

 

 

 

Taxes Recoverable Through Future Rates (net)

 

 

250

 

 

 

201

 

 

 

GPRC-CEF-EE

 

 

214

 

 

 

139

 

 

 

Pension Costs

 

 

193

 

 

 

189

 

 

 

Operating Leases

 

 

34

 

 

 

38

 

 

 

Other

 

 

278

 

 

 

291

 

 

 

Total Liabilities

 

$

7,781

 

 

$

7,277

 

 

 

Summary of Accumulated Deferred Income Taxes:

 

 

 

 

 

 

 

 

Net Deferred Income Tax Liabilities

 

$

7,190

 

 

$

6,608

 

 

 

ITC

 

 

58

 

 

 

63

 

 

 

Net Total Deferred Income Taxes and ITC

 

$

7,248

 

 

$

6,671

 

 

 

 

 

 

 

 

 

 

 

 

The deferred tax effect of certain assets and liabilities is presented in the table above net of the deferred tax effect associated with the respective regulatory deferrals.

A reconciliation of reported income tax expense for PSE&G with the amount computed by multiplying pre-tax income by the statutory federal income tax rate of 21% is as follows:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Years Ended December 31,

 

 

 

PSE&G

 

2024

 

 

2023

 

 

2022

 

 

 

 

 

Millions

 

 

 

Net Income

 

$

1,547

 

 

$

1,515

 

 

$

1,565

 

 

 

Income Taxes:

 

 

 

 

 

 

 

 

 

 

 

Operating Income:

 

 

 

 

 

 

 

 

 

 

 

Current Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

(67

)

 

$

127

 

 

$

130

 

 

 

State

 

 

 

 

 

4

 

 

 

 

 

 

Total Current

 

 

(67

)

 

 

131

 

 

 

130

 

 

 

Deferred Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

209

 

 

 

(113

)

 

 

(17

)

 

 

State

 

 

162

 

 

 

149

 

 

 

159

 

 

 

Total Deferred

 

 

371

 

 

 

36

 

 

 

142

 

 

 

ITC

 

 

(6

)

 

 

(7

)

 

 

(5

)

 

 

Total Income Tax Expense

 

$

298

 

 

$

160

 

 

$

267

 

 

 

Pre-Tax Income

 

$

1,845

 

 

$

1,675

 

 

$

1,832

 

 

 

Tax Computed at Statutory Rate @ 21%

 

$

387

 

 

$

352

 

 

$

385

 

 

 

Increase (Decrease) Attributable to Flow-Through of Certain Tax Adjustments:

 

 

 

 

 

 

 

 

 

 

 

State Income Taxes (net of federal income tax)

 

 

128

 

 

 

121

 

 

 

126

 

 

 

Uncertain Tax Positions

 

 

 

 

 

(9

)

 

 

2

 

 

 

Plant-Related Items

 

 

5

 

 

 

(7

)

 

 

(6

)

 

 

Tax Credits

 

 

(9

)

 

 

(9

)

 

 

(9

)

 

 

GPRC-CEF-EE

 

 

(52

)

 

 

(52

)

 

 

(37

)

 

 

TAC

 

 

(145

)

 

 

(232

)

 

 

(193

)

 

 

Bad Debt Flow-Through

 

 

(14

)

 

 

(9

)

 

 

(1

)

 

 

Other

 

 

(2

)

 

 

5

 

 

 

 

 

 

Subtotal

 

 

(89

)

 

 

(192

)

 

 

(118

)

 

 

Total Income Tax Expense

 

$

298

 

 

$

160

 

 

$

267

 

 

 

Effective Income Tax Rate

 

 

16.2

%

 

 

9.6

%

 

 

14.6

%

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The following is an analysis of deferred income taxes for PSE&G:

 

 

 

 

 

 

 

 

 

 

 

 

 

As of December 31,

 

 

 

PSE&G

 

2024

 

 

2023

 

 

 

 

 

Millions

 

 

 

Deferred Income Taxes

 

 

 

 

 

 

 

 

Assets:

 

 

 

 

 

 

 

 

Regulatory Liability Excess Deferred Tax

 

$

314

 

 

$

339

 

 

 

OPEB

 

 

22

 

 

 

28

 

 

 

CAMT Credit Carryforward

 

 

 

 

 

106

 

 

 

Bad Debt

 

 

43

 

 

 

57

 

 

 

Operating Leases

 

 

20

 

 

 

22

 

 

 

Other

 

 

54

 

 

 

60

 

 

 

Total Assets

 

$

453

 

 

$

612

 

 

 

Liabilities:

 

 

 

 

 

 

 

 

Plant-Related Items

 

$

4,631

 

 

$

4,396

 

 

 

New Jersey Corporate Business Tax

 

 

1,303

 

 

 

1,160

 

 

 

Pension Costs

 

 

199

 

 

 

198

 

 

 

Taxes Recoverable Through Future Rates (net)

 

 

250

 

 

 

201

 

 

 

GPRC-CEF-EE

 

 

214

 

 

 

139

 

 

 

Conservation Costs

 

 

103

 

 

 

88

 

 

 

Operating Leases

 

 

20

 

 

 

21

 

 

 

Other

 

 

152

 

 

 

158

 

 

 

Total Liabilities

 

$

6,872

 

 

$

6,361

 

 

 

Summary of Accumulated Deferred Income Taxes:

 

 

 

 

 

 

 

 

Net Deferred Income Tax Liabilities

 

$

6,419

 

 

$

5,749

 

 

 

ITC

 

 

58

 

 

 

64

 

 

 

Net Total Deferred Income Taxes and ITC

 

$

6,477

 

 

$

5,813

 

 

 

 

 

 

 

 

 

 

 

 

The deferred tax effect of certain assets and liabilities is presented in the table above net of the deferred tax effect associated with the respective regulatory deferrals.

PSEG and PSE&G each provide deferred taxes at the enacted statutory tax rate for all temporary differences between the financial statement carrying amounts and the tax bases of assets and liabilities irrespective of the treatment for rate-making purposes. Management believes that it is probable that the accumulated tax benefits that previously have been treated as a flow-through item to PSE&G customers will be recovered from or refunded to PSE&G’s customers in the future. See Note 6. Regulatory Assets and Liabilities.

The 2018 decrease in the federal tax rate resulted in PSE&G recording excess deferred income taxes. As of December 31, 2024, the remaining balance of excess deferred income taxes is all protected and was approximately $1.3 billion with a Regulatory Liability of approximately $1.8 billion. In 2024, PSE&G returned approximately $202 million of excess deferred income taxes and previously realized and current period deferred income taxes related to tax repair deductions to its customers with a reduction to tax expense of approximately $145 million. The flowback to customers of the excess deferred income taxes and previously realized tax repair deductions resulted in a decrease of approximately $122 million in the Regulatory Liability. The current period tax repair deduction reduces tax expense and revenue and recognizes a Regulatory Asset as PSE&G believes it is probable that the current period tax repair deductions flowed through to the customers will be recovered from customers in the future. See Note 6. Regulatory Assets and Liabilities for additional information.

In August 2022, the Inflation Reduction Act (IRA) was signed into law. The IRA enacted a 15% corporate alternative minimum tax (CAMT), which is based on adjusted financial statement income, effective in 2023, and made certain changes to existing energy tax credit laws.

PSEG has determined that it is not subject to the CAMT for 2023 and 2024 as it is not an applicable corporation in accordance with the statute. In September 2024, the U.S. Treasury issued proposed CAMT regulations on which taxpayers are not required to rely. The proposed CAMT regulations and certain relevant rules remain unclear and require further guidance. As such, the impact of the CAMT on PSEG’s and PSE&G’s financial statements is subject to continued evaluation.

The IRA established a new PTC for existing qualified nuclear generation facilities, effective 2024 through 2032, a new technology neutral energy tax credit, inclusive of both new nuclear units and increases to nuclear generation capacity, effective 2025, and the transferability of energy tax credits, effective 2023. The PTC for a given nuclear facility can be multiplied by five if prevailing wage requirements are met, and the value of the PTC is designed to phase down as the facility’s gross receipts increase. Both the PTC rate and reduction amount are subject to the Internal Revenue Service’s determination of annual inflation.

For the year ended December 31, 2024, PSEG recorded an income tax benefit associated with PTCs of approximately $350 million. PSEG also recorded an $89 million unrecognized tax benefit, which would affect the effective tax rate if recognized, since the PTCs recorded constitute an uncertain tax position and are subject to change when authoritative guidance is issued by the U.S. Treasury, particularly related to the definition of "gross receipts". Such guidance could result in a material increase or decrease in the net PTC recorded. Further, ZEC revenue has been reduced by the estimated PTCs generated from PSEG Power’s Salem 1, Salem 2, and Hope Creek nuclear plants for the year ended December 31, 2024. ZEC revenue will be adjusted based upon the actual value of the PTCs generated. See Note 2. Revenues for additional information.

Despite the issuance of proposed regulations and various Notices that provide interim guidance on numerous provisions of the IRA, many aspects of the IRA, including the PTCs and the CAMT, remain unclear and are in need of further guidance; therefore, the impact of several provisions of the IRA will have on PSEG's and PSE&G's financial statements is subject to continued evaluation.

The enactment of additional federal or state tax legislation and clarification of previously enacted tax laws could impact PSEG’s and PSE&G’s financial statements.

In April 2023, the U.S. Treasury issued Revenue Procedure 2023-15 that provides a safe harbor method of accounting to determine the annual repair tax deduction for gas T&D property. The impact, if any, this may have on PSEG and PSE&G’s financial statements is subject to continued evaluation and has not yet been determined.

As of December 31, 2024, PSEG had a $26 million state NOL and PSE&G had a $108 million New Jersey Corporate Business Tax NOL that are both expected to be fully realized in the future.

PSEG recorded the following amounts related to its unrecognized tax benefits, which were primarily comprised of amounts recorded for PSE&G and PSEG’s other subsidiaries:

 

 

 

 

 

 

 

 

 

 

 

2024

 

PSEG

 

 

PSE&G

 

 

 

 

 

Millions

 

 

 

Total Amount of Unrecognized Tax Benefits as of January 1, 2024

 

$

110

 

 

$

11

 

 

 

Increases as a Result of Positions Taken in a Prior Period

 

 

18

 

 

 

 

 

 

Decreases as a Result of Positions Taken in a Prior Period

 

 

(4

)

 

 

(3

)

 

 

Increases as a Result of Positions Taken during the Current Period

 

 

90

 

 

 

1

 

 

 

Decreases as a Result of Positions Taken during the Current Period

 

 

 

 

 

 

 

 

Decreases as a Result of Settlements with Taxing Authorities

 

 

(4

)

 

 

 

 

 

Decreases due to Lapses of Applicable Statute of Limitations

 

 

(1

)

 

 

(1

)

 

 

Total Amount of Unrecognized Tax Benefits as of December 31, 2024

 

$

209

 

 

$

8

 

 

 

Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits

 

 

(30

)

 

 

(5

)

 

 

Regulatory Asset—Unrecognized Tax Benefits

 

 

(1

)

 

 

(1

)

 

 

Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)

 

$

178

 

 

$

2

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2023

 

PSEG

 

 

PSE&G

 

 

 

 

 

Millions

 

 

 

Total Amount of Unrecognized Tax Benefits as of January 1, 2023

 

$

130

 

 

$

29

 

 

 

Increases as a Result of Positions Taken in a Prior Period

 

 

16

 

 

 

2

 

 

 

Decreases as a Result of Positions Taken in a Prior Period

 

 

(25

)

 

 

(12

)

 

 

Increases as a Result of Positions Taken during the Current Period

 

 

 

 

 

 

 

 

Decreases as a Result of Positions Taken during the Current Period

 

 

 

 

 

 

 

 

Decreases as a Result of Settlements with Taxing Authorities

 

 

(10

)

 

 

(7

)

 

 

Decreases due to Lapses of Applicable Statute of Limitations

 

 

(1

)

 

 

(1

)

 

 

Total Amount of Unrecognized Tax Benefits as of December 31, 2023

 

$

110

 

 

$

11

 

 

 

Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits

 

 

(29

)

 

 

(7

)

 

 

Regulatory Asset—Unrecognized Tax Benefits

 

 

(2

)

 

 

(2

)

 

 

Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)

 

$

79

 

 

$

2

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2022

 

PSEG

 

 

PSE&G

 

 

 

 

 

Millions

 

 

 

Total Amount of Unrecognized Tax Benefits as of January 1, 2022

 

$

192

 

 

$

27

 

 

 

Increases as a Result of Positions Taken in a Prior Period

 

 

9

 

 

 

2

 

 

 

Decreases as a Result of Positions Taken in a Prior Period

 

 

(40

)

 

 

(2

)

 

 

Increases as a Result of Positions Taken during the Current Period

 

 

1

 

 

 

1

 

 

 

Decreases as a Result of Positions Taken during the Current Period

 

 

 

 

 

 

 

 

Decreases as a Result of Settlements with Taxing Authorities

 

 

(28

)

 

 

 

 

 

Decreases due to Lapses of Applicable Statute of Limitations

 

 

(4

)

 

 

1

 

 

 

Total Amount of Unrecognized Tax Benefits as of December 31, 2022

 

$

130

 

 

$

29

 

 

 

Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits

 

 

(37

)

 

 

(15

)

 

 

Regulatory Asset—Unrecognized Tax Benefits

 

 

(8

)

 

 

(8

)

 

 

Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)

 

$

85

 

 

$

6

 

 

 

 

 

 

 

 

 

 

 

 

In 2022, the IRS approved PSEG’s 2018 carryback claim, which resulted in the closure of PSEG’s federal tax years through 2018.

PSEG and its subsidiaries include accrued interest and penalties related to uncertain tax positions required to be recorded as Income Tax Expense in the Consolidated Statements of Operations. Accumulated interest and penalties that are recorded on the Consolidated Balance Sheets on uncertain tax positions were as follows:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Accumulated Interest and Penalties
on Uncertain Tax Positions
as of December 31,

 

 

 

 

 

2024

 

 

2023

 

 

2022

 

 

 

 

 

Millions

 

 

 

PSEG

 

$

27

 

 

$

25

 

 

$

38

 

 

 

PSE&G

 

$

 

 

$

1

 

 

$

8

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

It is reasonably possible that total unrecognized tax benefits will significantly increase or decrease within the next twelve months due to either agreements with various taxing authorities upon audit, the expiration of the Statute of Limitations, or other pending tax matters. These potential increases or decreases are as follows:

 

 

 

 

 

 

 

 

Possible Decrease in Total Unrecognized Tax Benefits

 

Over the next
12 Months

 

 

 

 

 

Millions

 

 

 

PSEG

 

$

28

 

 

 

PSE&G

 

$

 

 

 

 

 

 

 

 

 

Description of income tax years that remain subject to examination by material jurisdictions, where an examination has not already concluded are:

 

 

 

 

 

 

 

 

 

 

 

PSEG

 

PSE&G

 

 

United States

 

 

 

 

 

 

Federal

 

2021-2023

 

N/A

 

 

New Jersey

 

2011-2023

 

2015-2023

 

 

Pennsylvania

 

2017-2023

 

2021-2023

 

 

Connecticut

 

2021-2022

 

N/A

 

 

Maryland

 

2021-2022

 

N/A

 

 

New York

 

2017-2023

 

N/A

 

 

 

 

 

 

 

 

Public Service Electric and Gas Company [Member]  
Income Taxes [Line Items]  
Income Taxes

Note 20. Income Taxes

A reconciliation of reported income tax expense for PSEG with the amount computed by multiplying pre-tax income by the statutory federal income tax rate of 21% is as follows:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Years Ended December 31,

 

 

 

PSEG

 

2024

 

 

2023

 

 

2022

 

 

 

 

 

Millions

 

 

 

Net Income

 

$

1,772

 

 

$

2,563

 

 

$

1,031

 

 

 

Income Taxes:

 

 

 

 

 

 

 

 

 

 

 

Operating Income:

 

 

 

 

 

 

 

 

 

 

 

Current Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

(225

)

 

$

144

 

 

$

262

 

 

 

State

 

 

15

 

 

 

19

 

 

 

(30

)

 

 

Total Current

 

 

(210

)

 

 

163

 

 

 

232

 

 

 

Deferred Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

129

 

 

 

109

 

 

 

(335

)

 

 

State

 

 

140

 

 

 

253

 

 

 

80

 

 

 

Total Deferred

 

 

269

 

 

 

362

 

 

 

(255

)

 

 

ITC

 

 

(6

)

 

 

(7

)

 

 

(6

)

 

 

Total Income Tax Expense (Benefit)

 

$

53

 

 

$

518

 

 

$

(29

)

 

 

Pre-Tax Income

 

$

1,825

 

 

$

3,081

 

 

$

1,002

 

 

 

Tax Computed at Statutory Rate @ 21%

 

$

383

 

 

$

647

 

 

$

210

 

 

 

Increase (Decrease) Attributable to Flow-Through of Certain Tax Adjustments:

 

 

 

 

 

 

 

 

 

 

 

State Income Taxes (net of federal income tax)

 

 

122

 

 

 

215

 

 

 

41

 

 

 

Uncertain Tax Positions

 

 

95

 

 

 

(14

)

 

 

(22

)

 

 

NDT Fund

 

 

21

 

 

 

26

 

 

 

(22

)

 

 

Plant-Related Items

 

 

5

 

 

 

(7

)

 

 

(6

)

 

 

Tax Credits

 

 

(361

)

 

 

(10

)

 

 

(10

)

 

 

Audit Settlement

 

 

 

 

 

(7

)

 

 

 

 

 

Leasing Activities

 

 

 

 

 

(22

)

 

 

 

 

 

GPRC-CEF-EE

 

 

(52

)

 

 

(52

)

 

 

(37

)

 

 

TAC

 

 

(145

)

 

 

(232

)

 

 

(193

)

 

 

Bad Debt Flow-Through

 

 

(14

)

 

 

(9

)

 

 

(1

)

 

 

Other

 

 

(1

)

 

 

(17

)

 

 

11

 

 

 

Subtotal

 

 

(330

)

 

 

(129

)

 

 

(239

)

 

 

Total Income Tax Expense (Benefit)

 

$

53

 

 

$

518

 

 

$

(29

)

 

 

Effective Income Tax Rate

 

 

2.9

%

 

 

16.8

%

 

 

(2.9

)%

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The following is an analysis of deferred income taxes for PSEG:

 

 

 

 

 

 

 

 

 

 

 

 

 

As of December 31,

 

 

 

PSEG

 

2024

 

 

2023

 

 

 

 

 

Millions

 

 

 

Deferred Income Taxes

 

 

 

 

 

 

 

 

Assets:

 

 

 

 

 

 

 

 

Regulatory Liability Excess Deferred Tax

 

$

314

 

 

$

339

 

 

 

OPEB

 

 

49

 

 

 

58

 

 

 

Bad Debt

 

 

43

 

 

 

57

 

 

 

Corporate Alternative Minimum Tax (CAMT) Credit Carryforward

 

 

 

 

 

44

 

 

 

Operating Leases

 

 

38

 

 

 

42

 

 

 

Other

 

 

147

 

 

 

129

 

 

 

Total Assets

 

$

591

 

 

$

669

 

 

 

 

 

 

 

 

 

 

 

 

Liabilities:

 

 

 

 

 

 

 

 

Plant-Related Items

 

$

5,084

 

 

$

4,850

 

 

 

New Jersey Corporate Business Tax

 

 

1,414

 

 

 

1,284

 

 

 

Leasing Activities

 

 

33

 

 

 

35

 

 

 

AROs and NDT Fund

 

 

281

 

 

 

250

 

 

 

Taxes Recoverable Through Future Rates (net)

 

 

250

 

 

 

201

 

 

 

GPRC-CEF-EE

 

 

214

 

 

 

139

 

 

 

Pension Costs

 

 

193

 

 

 

189

 

 

 

Operating Leases

 

 

34

 

 

 

38

 

 

 

Other

 

 

278

 

 

 

291

 

 

 

Total Liabilities

 

$

7,781

 

 

$

7,277

 

 

 

Summary of Accumulated Deferred Income Taxes:

 

 

 

 

 

 

 

 

Net Deferred Income Tax Liabilities

 

$

7,190

 

 

$

6,608

 

 

 

ITC

 

 

58

 

 

 

63

 

 

 

Net Total Deferred Income Taxes and ITC

 

$

7,248

 

 

$

6,671

 

 

 

 

 

 

 

 

 

 

 

 

The deferred tax effect of certain assets and liabilities is presented in the table above net of the deferred tax effect associated with the respective regulatory deferrals.

A reconciliation of reported income tax expense for PSE&G with the amount computed by multiplying pre-tax income by the statutory federal income tax rate of 21% is as follows:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Years Ended December 31,

 

 

 

PSE&G

 

2024

 

 

2023

 

 

2022

 

 

 

 

 

Millions

 

 

 

Net Income

 

$

1,547

 

 

$

1,515

 

 

$

1,565

 

 

 

Income Taxes:

 

 

 

 

 

 

 

 

 

 

 

Operating Income:

 

 

 

 

 

 

 

 

 

 

 

Current Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

(67

)

 

$

127

 

 

$

130

 

 

 

State

 

 

 

 

 

4

 

 

 

 

 

 

Total Current

 

 

(67

)

 

 

131

 

 

 

130

 

 

 

Deferred Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

209

 

 

 

(113

)

 

 

(17

)

 

 

State

 

 

162

 

 

 

149

 

 

 

159

 

 

 

Total Deferred

 

 

371

 

 

 

36

 

 

 

142

 

 

 

ITC

 

 

(6

)

 

 

(7

)

 

 

(5

)

 

 

Total Income Tax Expense

 

$

298

 

 

$

160

 

 

$

267

 

 

 

Pre-Tax Income

 

$

1,845

 

 

$

1,675

 

 

$

1,832

 

 

 

Tax Computed at Statutory Rate @ 21%

 

$

387

 

 

$

352

 

 

$

385

 

 

 

Increase (Decrease) Attributable to Flow-Through of Certain Tax Adjustments:

 

 

 

 

 

 

 

 

 

 

 

State Income Taxes (net of federal income tax)

 

 

128

 

 

 

121

 

 

 

126

 

 

 

Uncertain Tax Positions

 

 

 

 

 

(9

)

 

 

2

 

 

 

Plant-Related Items

 

 

5

 

 

 

(7

)

 

 

(6

)

 

 

Tax Credits

 

 

(9

)

 

 

(9

)

 

 

(9

)

 

 

GPRC-CEF-EE

 

 

(52

)

 

 

(52

)

 

 

(37

)

 

 

TAC

 

 

(145

)

 

 

(232

)

 

 

(193

)

 

 

Bad Debt Flow-Through

 

 

(14

)

 

 

(9

)

 

 

(1

)

 

 

Other

 

 

(2

)

 

 

5

 

 

 

 

 

 

Subtotal

 

 

(89

)

 

 

(192

)

 

 

(118

)

 

 

Total Income Tax Expense

 

$

298

 

 

$

160

 

 

$

267

 

 

 

Effective Income Tax Rate

 

 

16.2

%

 

 

9.6

%

 

 

14.6

%

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The following is an analysis of deferred income taxes for PSE&G:

 

 

 

 

 

 

 

 

 

 

 

 

 

As of December 31,

 

 

 

PSE&G

 

2024

 

 

2023

 

 

 

 

 

Millions

 

 

 

Deferred Income Taxes

 

 

 

 

 

 

 

 

Assets:

 

 

 

 

 

 

 

 

Regulatory Liability Excess Deferred Tax

 

$

314

 

 

$

339

 

 

 

OPEB

 

 

22

 

 

 

28

 

 

 

CAMT Credit Carryforward

 

 

 

 

 

106

 

 

 

Bad Debt

 

 

43

 

 

 

57

 

 

 

Operating Leases

 

 

20

 

 

 

22

 

 

 

Other

 

 

54

 

 

 

60

 

 

 

Total Assets

 

$

453

 

 

$

612

 

 

 

Liabilities:

 

 

 

 

 

 

 

 

Plant-Related Items

 

$

4,631

 

 

$

4,396

 

 

 

New Jersey Corporate Business Tax

 

 

1,303

 

 

 

1,160

 

 

 

Pension Costs

 

 

199

 

 

 

198

 

 

 

Taxes Recoverable Through Future Rates (net)

 

 

250

 

 

 

201

 

 

 

GPRC-CEF-EE

 

 

214

 

 

 

139

 

 

 

Conservation Costs

 

 

103

 

 

 

88

 

 

 

Operating Leases

 

 

20

 

 

 

21

 

 

 

Other

 

 

152

 

 

 

158

 

 

 

Total Liabilities

 

$

6,872

 

 

$

6,361

 

 

 

Summary of Accumulated Deferred Income Taxes:

 

 

 

 

 

 

 

 

Net Deferred Income Tax Liabilities

 

$

6,419

 

 

$

5,749

 

 

 

ITC

 

 

58

 

 

 

64

 

 

 

Net Total Deferred Income Taxes and ITC

 

$

6,477

 

 

$

5,813

 

 

 

 

 

 

 

 

 

 

 

 

The deferred tax effect of certain assets and liabilities is presented in the table above net of the deferred tax effect associated with the respective regulatory deferrals.

PSEG and PSE&G each provide deferred taxes at the enacted statutory tax rate for all temporary differences between the financial statement carrying amounts and the tax bases of assets and liabilities irrespective of the treatment for rate-making purposes. Management believes that it is probable that the accumulated tax benefits that previously have been treated as a flow-through item to PSE&G customers will be recovered from or refunded to PSE&G’s customers in the future. See Note 6. Regulatory Assets and Liabilities.

The 2018 decrease in the federal tax rate resulted in PSE&G recording excess deferred income taxes. As of December 31, 2024, the remaining balance of excess deferred income taxes is all protected and was approximately $1.3 billion with a Regulatory Liability of approximately $1.8 billion. In 2024, PSE&G returned approximately $202 million of excess deferred income taxes and previously realized and current period deferred income taxes related to tax repair deductions to its customers with a reduction to tax expense of approximately $145 million. The flowback to customers of the excess deferred income taxes and previously realized tax repair deductions resulted in a decrease of approximately $122 million in the Regulatory Liability. The current period tax repair deduction reduces tax expense and revenue and recognizes a Regulatory Asset as PSE&G believes it is probable that the current period tax repair deductions flowed through to the customers will be recovered from customers in the future. See Note 6. Regulatory Assets and Liabilities for additional information.

In August 2022, the Inflation Reduction Act (IRA) was signed into law. The IRA enacted a 15% corporate alternative minimum tax (CAMT), which is based on adjusted financial statement income, effective in 2023, and made certain changes to existing energy tax credit laws.

PSEG has determined that it is not subject to the CAMT for 2023 and 2024 as it is not an applicable corporation in accordance with the statute. In September 2024, the U.S. Treasury issued proposed CAMT regulations on which taxpayers are not required to rely. The proposed CAMT regulations and certain relevant rules remain unclear and require further guidance. As such, the impact of the CAMT on PSEG’s and PSE&G’s financial statements is subject to continued evaluation.

The IRA established a new PTC for existing qualified nuclear generation facilities, effective 2024 through 2032, a new technology neutral energy tax credit, inclusive of both new nuclear units and increases to nuclear generation capacity, effective 2025, and the transferability of energy tax credits, effective 2023. The PTC for a given nuclear facility can be multiplied by five if prevailing wage requirements are met, and the value of the PTC is designed to phase down as the facility’s gross receipts increase. Both the PTC rate and reduction amount are subject to the Internal Revenue Service’s determination of annual inflation.

For the year ended December 31, 2024, PSEG recorded an income tax benefit associated with PTCs of approximately $350 million. PSEG also recorded an $89 million unrecognized tax benefit, which would affect the effective tax rate if recognized, since the PTCs recorded constitute an uncertain tax position and are subject to change when authoritative guidance is issued by the U.S. Treasury, particularly related to the definition of "gross receipts". Such guidance could result in a material increase or decrease in the net PTC recorded. Further, ZEC revenue has been reduced by the estimated PTCs generated from PSEG Power’s Salem 1, Salem 2, and Hope Creek nuclear plants for the year ended December 31, 2024. ZEC revenue will be adjusted based upon the actual value of the PTCs generated. See Note 2. Revenues for additional information.

Despite the issuance of proposed regulations and various Notices that provide interim guidance on numerous provisions of the IRA, many aspects of the IRA, including the PTCs and the CAMT, remain unclear and are in need of further guidance; therefore, the impact of several provisions of the IRA will have on PSEG's and PSE&G's financial statements is subject to continued evaluation.

The enactment of additional federal or state tax legislation and clarification of previously enacted tax laws could impact PSEG’s and PSE&G’s financial statements.

In April 2023, the U.S. Treasury issued Revenue Procedure 2023-15 that provides a safe harbor method of accounting to determine the annual repair tax deduction for gas T&D property. The impact, if any, this may have on PSEG and PSE&G’s financial statements is subject to continued evaluation and has not yet been determined.

As of December 31, 2024, PSEG had a $26 million state NOL and PSE&G had a $108 million New Jersey Corporate Business Tax NOL that are both expected to be fully realized in the future.

PSEG recorded the following amounts related to its unrecognized tax benefits, which were primarily comprised of amounts recorded for PSE&G and PSEG’s other subsidiaries:

 

 

 

 

 

 

 

 

 

 

 

2024

 

PSEG

 

 

PSE&G

 

 

 

 

 

Millions

 

 

 

Total Amount of Unrecognized Tax Benefits as of January 1, 2024

 

$

110

 

 

$

11

 

 

 

Increases as a Result of Positions Taken in a Prior Period

 

 

18

 

 

 

 

 

 

Decreases as a Result of Positions Taken in a Prior Period

 

 

(4

)

 

 

(3

)

 

 

Increases as a Result of Positions Taken during the Current Period

 

 

90

 

 

 

1

 

 

 

Decreases as a Result of Positions Taken during the Current Period

 

 

 

 

 

 

 

 

Decreases as a Result of Settlements with Taxing Authorities

 

 

(4

)

 

 

 

 

 

Decreases due to Lapses of Applicable Statute of Limitations

 

 

(1

)

 

 

(1

)

 

 

Total Amount of Unrecognized Tax Benefits as of December 31, 2024

 

$

209

 

 

$

8

 

 

 

Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits

 

 

(30

)

 

 

(5

)

 

 

Regulatory Asset—Unrecognized Tax Benefits

 

 

(1

)

 

 

(1

)

 

 

Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)

 

$

178

 

 

$

2

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2023

 

PSEG

 

 

PSE&G

 

 

 

 

 

Millions

 

 

 

Total Amount of Unrecognized Tax Benefits as of January 1, 2023

 

$

130

 

 

$

29

 

 

 

Increases as a Result of Positions Taken in a Prior Period

 

 

16

 

 

 

2

 

 

 

Decreases as a Result of Positions Taken in a Prior Period

 

 

(25

)

 

 

(12

)

 

 

Increases as a Result of Positions Taken during the Current Period

 

 

 

 

 

 

 

 

Decreases as a Result of Positions Taken during the Current Period

 

 

 

 

 

 

 

 

Decreases as a Result of Settlements with Taxing Authorities

 

 

(10

)

 

 

(7

)

 

 

Decreases due to Lapses of Applicable Statute of Limitations

 

 

(1

)

 

 

(1

)

 

 

Total Amount of Unrecognized Tax Benefits as of December 31, 2023

 

$

110

 

 

$

11

 

 

 

Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits

 

 

(29

)

 

 

(7

)

 

 

Regulatory Asset—Unrecognized Tax Benefits

 

 

(2

)

 

 

(2

)

 

 

Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)

 

$

79

 

 

$

2

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2022

 

PSEG

 

 

PSE&G

 

 

 

 

 

Millions

 

 

 

Total Amount of Unrecognized Tax Benefits as of January 1, 2022

 

$

192

 

 

$

27

 

 

 

Increases as a Result of Positions Taken in a Prior Period

 

 

9

 

 

 

2

 

 

 

Decreases as a Result of Positions Taken in a Prior Period

 

 

(40

)

 

 

(2

)

 

 

Increases as a Result of Positions Taken during the Current Period

 

 

1

 

 

 

1

 

 

 

Decreases as a Result of Positions Taken during the Current Period

 

 

 

 

 

 

 

 

Decreases as a Result of Settlements with Taxing Authorities

 

 

(28

)

 

 

 

 

 

Decreases due to Lapses of Applicable Statute of Limitations

 

 

(4

)

 

 

1

 

 

 

Total Amount of Unrecognized Tax Benefits as of December 31, 2022

 

$

130

 

 

$

29

 

 

 

Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits

 

 

(37

)

 

 

(15

)

 

 

Regulatory Asset—Unrecognized Tax Benefits

 

 

(8

)

 

 

(8

)

 

 

Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)

 

$

85

 

 

$

6

 

 

 

 

 

 

 

 

 

 

 

 

In 2022, the IRS approved PSEG’s 2018 carryback claim, which resulted in the closure of PSEG’s federal tax years through 2018.

PSEG and its subsidiaries include accrued interest and penalties related to uncertain tax positions required to be recorded as Income Tax Expense in the Consolidated Statements of Operations. Accumulated interest and penalties that are recorded on the Consolidated Balance Sheets on uncertain tax positions were as follows:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Accumulated Interest and Penalties
on Uncertain Tax Positions
as of December 31,

 

 

 

 

 

2024

 

 

2023

 

 

2022

 

 

 

 

 

Millions

 

 

 

PSEG

 

$

27

 

 

$

25

 

 

$

38

 

 

 

PSE&G

 

$

 

 

$

1

 

 

$

8

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

It is reasonably possible that total unrecognized tax benefits will significantly increase or decrease within the next twelve months due to either agreements with various taxing authorities upon audit, the expiration of the Statute of Limitations, or other pending tax matters. These potential increases or decreases are as follows:

 

 

 

 

 

 

 

 

Possible Decrease in Total Unrecognized Tax Benefits

 

Over the next
12 Months

 

 

 

 

 

Millions

 

 

 

PSEG

 

$

28

 

 

 

PSE&G

 

$

 

 

 

 

 

 

 

 

 

Description of income tax years that remain subject to examination by material jurisdictions, where an examination has not already concluded are:

 

 

 

 

 

 

 

 

 

 

 

PSEG

 

PSE&G

 

 

United States

 

 

 

 

 

 

Federal

 

2021-2023

 

N/A

 

 

New Jersey

 

2011-2023

 

2015-2023

 

 

Pennsylvania

 

2017-2023

 

2021-2023

 

 

Connecticut

 

2021-2022

 

N/A

 

 

Maryland

 

2021-2022

 

N/A

 

 

New York

 

2017-2023

 

N/A